fort monroe

RAB Meeting

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1 Feb 2007
Agenda

I. Call to Order - 6:00 PM

II. Roll Call

III. Amendment/Approval of Minutes, 16 November 2006

IV. Old Business

Operating Procedures (Clarification of DoD contractors)
Conflict of Interest
Information Resources

V. New Business

CERCLA Training
Document Review
Way Ahead

VI. Adjournment - Next Meeting 3 May 2007

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Information Resources

• Information Repository in Hampton Public
Library:

- 2006 Notebook (Fact Sheet, Survey, Agenda &
Minutes, Operating Procedures, Guidance)

- Historical Records Review

- Environmental Condition of Property

• RAB Web Site (under construction):

- http://147.248. 251. 93/mon roe/sites/local/default, a
sp

CERCLA 101 Training
and the
Fort Monroe
Environmental
Restoration Program

February 1, 2007

Background

Prior to the 1970s, commonly accepted
practices used to dispose of hazardous
substances consisted of burials and discharges.

The full environmental and public health risks
associated with these practices were not known.

- Love Canal, New York

- Cuyahoga River, Great Lakes

Similar events helped spur environmental
laws and the creation of federal and state
environmental protection agencies.

Legal Authorities and
Organization

Laws/Statutes - Congress creates legal
requirements.

- Most environmental legislation is codified in Title 42,
“Public Health and Welfare" in the United States Code
(USC)

Regulations/Rules - Executive Branch interprets
and adds technical judgment to implement the
legal requirements.

- The Environmental Protection Agency (EPA) regulations
are found in Title 40, "Protection of Environment" in the
Code of Federal Regulations (CFR)

Executive Orders (EO)- The President can delegate
certain Presidential authorities to Federal agencies.

Laws

The Resources Conservation and Recovery Act
(RCRA) was enacted by Congress in 1976.

- RCRA requires control of hazardous wastes from the point of
generation to their ultimate disposal or "cradle to grave"

- Final regulations for controlling hazardous wastes under
RCRA did not go into effect until 1980.

In 1980, Congress passed the Comprehensive
Environmental Response, Compensation and
Liability Act (CERCLA), commonly known as
"Superfund."

- CERCLA requires identification, investigation and cleanup of
sites contaminated by past releases of hazardous
substances, pollutants and contaminants.

- Implementing regulations found in 40 CFR 300, National Oil
and Hazardous Substances Pollution Contingency Plan
(NCP)

■HIM 1IIIWIIIMIMII

CERCLA Cleanup process

The cleanup process consists of several phases:

• Preliminary Assessment/Site Inspection (PA/SI)

- investigations of site conditions

• HRS Scoring

- The score is based on factors that relate to risk based on
conditions at the site.

- screening mechanism used to place sites on the National
Priorities List (NPL), the list of the most serious sites identified
for possible long-term cleanup

Remedial Investigation/Feasibility Study (RI/FS)

- determines the nature and extent of contamination

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Cleanup process - Cont'd

Records of Decision (ROD)/Decision Document
(DD)

- explains which cleanup alternatives will be used (ROD at
NPL sites, DD at non-NPL sites)

Remedial Design/Remedial Action (RD/RA)

- preparation and implementation of plans and
specifications for applying site remedies

Response Complete (RC)

- identifies completion of cleanup activities

Long-Term Management

- ensures response actions provide long-term protection of
human heafth and the environment.

Overview of the Superfund Process

Discovery and
Notification

Urgent?
Yes J

A I

COMMUNITY INVOLVEMENT

Referral to Remedial
■ Additional Threats?

On-Scene

Coordinator

Emergency

<0

-•*

Action Memo

Time Critical
Removal

Engineering
Evaluation and
Cost Analysis
Approval Memo

Action M

EB

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Note: At any given time, a remedial project can be referred to the removal program, and vice-versa

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Information Resources

EPA Web Site:

Defense Environmental Network Information
Exchange (DENIX):

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Defense Environmental
Restoration Program (DERP)

• In 1986, the Superfund Amendments and
Reauthorization Act (SARA, 10 USC 2701)
amended CERCLA and established the DERP.

• SARA authorizes Secretary of Defense to carry out
the DERP at DoD facilities

- EO 12580, Superfund Implementation, January 23, 1986

- EO 13016, Superfund Amendments, August 28, 1996

• Response actions taken under DERP to address
releases must be conducted IAW the provisions of
CERCLA 120 (42 USC 9620).

DERP - Cont'd

DERP categories:

• Installation Restoration Program (IRP)

- environmental responses to hazardous substances,
pollutants, contaminants and petroleum, oils and
lubricants (POL).

• Military Munitions Response Program (MMRP)

- environmental responses to non-operational ranges
known or suspected to contain munitions and
explosives of concern (MEC).

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Status of Fort Monroe IRP

• PA completed September 1990 and sent to EPA

in October 1990

- 29 locations identified based on a July 1990 Property
Report

• PA Addendum completed March 1992 to address

HRS checklist deficiencies.

• Four Sites carried forward into DERP database

- 2 former landfills, classified document incinerator, UXO Post-
wide

• si (?)

- One round of groundwater samples collected/analyzed
May 1992 at two former landfills.

- No documentation found to indicate if any sampling occurred
at the classified document incinerator

- Geophysical survey conducted in 1994 post-wide for
presence of UXO

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Cont'd

Geophysical survey report entitled Ordnance and
Explosive Waste (OEW) Investigation, Evaluation
and Prioritization (Parsons, 1995) was conducted
per direction by BRAC 1993 Commission

Findings and Conclusions

- 73,331 anomalies detected, 79,900 more estimated in
moat

- 581 anomalies investigated, 7 cannonballs found

- Estimated 21851 (29.8%) of anomalies have the
potential to be ordnance

- Estimated 1309 (1.8%) of anomalies will be UXO

• IRP sites listed as Response Complete in
DERP database

- Landfills & incinerator in 1992

- UXO Post-wide in 1995

• Unknown if HRS scoring occurred

I i

Military Munitions Response
Program (MMRP)

• DoD and EPA agree that human health,
environmental and explosive safety concerns at
these sites need to be evaluated and
addressed.

• National Defense Authorization Act for FY02
established the MMRP, a new program element
of DERP for cleanup of property known, or
suspected, to contain munitions and explosives
of concern (MEC).

• MEC includes:

- Unexploded ordnance (UXO)

- Discarded military munitions (DMM) and/or

- Munitions constituents (MC).

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MMRP

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• The MMRP integrates, to the extent
practicable, explosives safety and
environmental requirements to protect
public safety, human health and the
environment.

• MEC differs from hazardous, toxic, and
radiological wastes (HTRW), substances
covered in the IRP, as it presents an
immediate risk of physical injury while
HTRW generally present a threat to
human health and environment through
repeated and accumulated exposure.

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MEC vs. HTRW

General Characteristics

MEC HTRW

Not very mobile Very mobile

Not chemical specificChemical specific

Not concentration dependent Concentration dependent
Single exposure Multiple exposure

Narrow target population Broad target population
Immediate acute physical Long-term health effects
injury

MMRP

Additional review and approvals required for
MMRP response actions by the United States
Army Technical Center for Explosive Safety
(USATCES) and the DoD Explosives Safety Board
(DDESB).

USATCES:

- Develops Army policies, procedures and regulations to
ensure compliance with DoD Explosive Safety Standards

- Provides technical assistance and advise

- Provides Army approval of explosive safety submissions
and site plans

DDESB:

- Approves explosive safety submissions and site plans

- Approves explosives safety submissions of transfer
documents

MMRP

Monroe

Site-specific response actions generally follow
the CERCLA process.

Preliminary Assessment (PA) involves
recognizing the existence of the site,
identifying safety risks, and determining which
sites qualify for further investigation in MMRP.

- Closed, Transferred and Transferring (CTT)
Range/Site Inventory Report (Malcolm
Pirnie, 2003): 13 sites identified

Fort Monroe MMRP - Cont'd

Site Inspection (SI) involves a research of
historical records in order to prioritize
sites

- Historical Records Review (Malcolm Pirnie,
2006):

• Included all sites that had ordnance-
related activities, not just MMRP-eligible
sites

• 57 sites identified, 44 recommended for
further investigation

Army BRAC

Environmental Restoration
Program (ERP)

DERP refers to the entire DoD program.

Army BRAC ERP refers to Army BRAC
installations.

- A comprehensive program to identify, investigate and
clean up contamination, to include MEC, at Army
installations designated for closure under BRAC.

- BRAC ERP goal is to protect human health and the
environment by cleaning up sites as quickly as
resources permit to facilitate transfer of Army excess
properties for reuse.

- Restoration sites include those contaminated by past or
closing defense activities and where a response is
required by CERCLA, RCRA and the Community
Environmental Response Facilitation Act (CERFA), which
is the identification of uncontaminated parcels of land.

Environmental Requirements

VMM 1 1 1

at Closing Army Installations

Restoration activities (IRP and MMRP cleanups)
and closure-related compliance

The National Environmental Policy Act (NEPA)
evaluation and documentation of potential
environmental impacts associated with
property disposal, transfer and reuse

Cultural and Natural Resource considerations

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Next Steps

Identify Areas of Concern (AOC) based on review
of historical uses of sites to determine if further
investigation is warranted

- Environmental Condition of Property (SAIC, November
2006 )

Site screening AOCs for HTRW issues

Rl Scoping for munitions issues

BRAC Installation Action Plan (BIAP)- a
management plan that identifies sites requiring
environmental restoration, establishes schedules
and identifies funding requirements.

Questions?

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Document Review

Current documents available (for review only):

• Historical Records Review (Malcolm Pirnie, Apr 2006)

• Environmental Condition of Property (SAIC, Nov 2006)

Future Documents For Review & Comment:

Work Plans

Remedial Investigations

Feasibility Studies

Proposed Plans

Decision Documents

Remedial Designs/Remedial Actions

Prioritization Protocol

BRAC Installation Action Plan - annual updates

Way Ahead

• National Environmental Policy Act

- Public scoping meeting comments due
March 1, 2007

- Environmental Assessment comment period:

July 9 through August 8, 2007

• BRAC Installation Action Plan Workshop

- Postponed

Munitions Training